A military charity with Ed Miliband and other MPs as patrons has to date spent only a tiny proportion of its income on charitable activities. Astonishingly, nothing was spent on charitable activities for two years – financial years ending 30 April 2012 and 30 April 2014. While the intervening year wasn’t much better: just 3.1% of the £31 957 income, £1000, went on charitable activities. What’s more, the most recent annual accounts, for financial year ending 30 April 2014, were “qualified” – and for a worrying reason. The chairman, also public contact, has at date of publication failed to provide a satisfactory explanation for the shameful record of spending – or not spending – on charitable activities. The fourth annual accounts are at date of publication overdue at the Charity Commission, itself a sign of a badly-run charity. In fact, The Forgotten Heroes failed to file its accounts on time twice in the previous three years. Two of three MP patrons replied to my enquiries – but neither was willing to account for the consistent underspending on charitable activities. Patron Ed Miliband MP, former Labour leader, didn’t reply to my emails. Nor did patrons The Proclaimers, the Scottish band.

Leeds-based charity The Forgotten Heroes (registered charity number: 1140819) was set up in 2011 by Adam Douglas, an injured Iraq War veteran. Its mission is “to provide the very best support and advice to the carers and families of wounded servicemen and women”, says the website: www.theforgottenheroes.org.uk. The charity isn’t a member of the official umbrella organisation for military charities, the Confederation of Service Charities (Cobseo).

The Forgotten Heroes has impressive and serious patrons, including several MPs fromdifferent parties; and, somewhat incongruously, The Proclaimers, the Scottish band.

Yet the charity has to date spent only a tiny proportion of its income on charitable activities. Astonishingly, nothing was spent on charitable activities for two years – financial years ending 30 April 2012 and 30 April 2014. While the intervening year wasn’t much better: just 3.1% of the £31 957 income, £1000, went on charitable activities.

What’s more, the most recent annual accounts, for financial year ending 30 April 2014, were “qualified” – and for a worrying reason. Qualified accounts are accounts questioned by an independent assessor. Here the independent examiner’s qualified statement is serious: “The trustees have prepared accounts which report income of £26 665 and expenditure of £21 900. However, limited records are available to support the transactions within the charity’s bank account upon which these accounts are based. The absence of accounting records follows a change in the composition of the board of trustees with the new board unable to locate the records maintained by the previous treasurer.” Clearly, the reason for the qualification raises serious questions about the charity and its management, financial and otherwise.

The chairman, also public contact, has at date of publication failed to provide a satisfactory explanation for the shameful record of spending – or not spending – on charitable activities. On 9 March 2016, David Sessions told me in an evasive email: “I can confirm that since I have taken over as chairman of the charity we have given away money to beneficiaries.” Well, yes, but the amount spent on charitable activities is pitiful, according to the three years of accounts filed at the Charity Commission. And Mr Sessions hasn’t just become chairman either. While the first year’s accounts show Mr Douglas as chairman, those for the second and third years list Mr Sessions in the role.

In the same email, Mr Sessions added that the charity was “moving offices at the moment”, but he‘d send “a factual and considered response… as soon as possible.” At date of publication I’ve received nothing.

Perhaps the charitable spending will improve in the fourth annual accounts. These are at date of publication overdue at the Charity Commission, itself a sign of a badly-run charity. In fact, The Forgotten Heroes failed to file its accounts on time twice in the previous three years.

Two of three MP patrons replied to my enquiries – but neither was willing to account for the consistent underspending on charitable activities. Both directed me to the trustees. The two are local MPs Greg Mulholland (Liberal Democrats) and Stuart Andrew (Conservatives). The latter is billed as “Stuart Andrews” [sic] on the charity website (screen shot in Figure 1). If they can’t get the name right…

Figure 1. Patron “Stuart Andrews” [sic] MP at 29 March 2016

Former Labour leader Ed Miliband MP, though, didn’t reply to my emails. The then party leader became a patron in November 2013, according to a report in the Yorkshire Evening Post newspaper. The Proclaimers, too, were unresponsive.

The Forgotten Heroes confirms my earlier observation that an MP patron is no guarantee a charity spends a reasonable proportion of its income on charitable activities. My first experience was with failed military charity Afghan Heroes, whose patrons included former defence secretary Dr Liam Fox MP (see my 6 January 2014 post). I encountered it again with Our Local Heroes Foundation, another military charity with excessive fundraising costs. There Ben Wallace MP, ex-military himself, was a patron – until apparently last summer when I noticed he’d disappeared from the charity website, without explanation, whereupon he also became unresponsive (see my 17 December 2015 post).

The public reasonably expectthat patrons, MPsespecially, have conducted due diligence on a charitythey endorse and are involved with. Yet the consistent underspending on charitable activities calls into question the judgement of the patrons of The Forgotten Heroes. The ridiculously low level of charitable expenditure is indefensible. And here again we observe patrons of a charity avoiding accountability – that’s if they even reply to emails.

A fund set up in memory of a Liverpool soldier killed in Afghanistan isn’t a registered charity, despite apparently raising tens of thousand pounds for a group of registered charities. Several concerns arise from this fact. Most importantly, the Charity Commission repeatedly advises the public to donate to registered charities only. What’s more, the fund refuses to say why it isn’t registered with the commission as a charity. Not a good sign. But the fund isn’t the only organisation unwilling to answer legitimate questions. The Royal British Legion, one of the UK’s most trusted charities, won’t say why it’s granted permission to the fund to raise money on its behalf when the latter isn’t a registered charity.

The Mark Burgan Memorial Fund (MBMF) was set up in memory of Mark Burgan, a Liverpool soldier killed in Afghanistan in March 2011: markburgan.com. It apparently raises money for a group ofregistered charities, including the Royal British Legion (registered charity number: 219279). Established in November 2011, the MBMF isn’t a registered charity. Several concerns arise from this fact.

Most importantly, the Charity Commission repeatedly advises the public to donate to registered charities only.

The MBMF sounds like it’s a charity and could be perceived as such. The Liverpool Echo newspaper, for example,erroneously referred to it as a “charity fund” in a May 2015 report: http://www.liverpoolecho.co.uk/news/liverpool-news/fund-set-up-memory-fallen-9349755. There are reputational benefits of being a registered charity. Registration is with the Charity Commission, the independent regulator of charities in England and Wales. The commission only registers charities satisfying various tests, particularly the public benefit test. As regulator, the Charity Commission has a responsibility to uphold trust and confidence in charities. Clearly, it’s problematic if the public perceives an organisation to be a registered charity when it isn’t one.

But this is about more than reputation and legitimacy. How can anyone know how much money is being raised – and how exactly the MBMF spends it? There‘s no transparency or accountability becausethe fund doesn’t file annual accounts for the public record unlike a charity at the Charity Commission. Further, the MBMF isn’t a registered company either, so again no annual accounts for the public record at Companies House. The MBMF is thus opaque and unaccountable.

The fund is unaccountable in another way. I’ve repeatedly asked the MBMF in emails why it isn’t a registered charity. No response. Not a good sign.

Someone else who won’t answer emails is Mark Pattison, the registrant of the domain name markburgan.com, according to the WHOIS information. Mr Pattison is a director of the company Northampton Marketing Ltd (registered company number: 04983922), whose registered office address is almost identical to the address on the “Contact Us” page for the MBMF. There are no names or phone number on the “Contact Us” page. Here it is at 25 February 2016: web.archive.org/web/20160225044940/http://markburgan.com/contact-us.php.

Incorporated 3 December 2003, all 11 annual accounts filed for Northampton Marketing Ltd at Companies House are for a dormant company. Althoughapparently dormant, the company is the registrant of the domain name northamptonmarketing.co.uk, according to the WHOIS information. Mr Pattison uses the domain for the website of his businessNorthampton Marketing – not to be confused with his registered company, Northampton Marketing Ltd. There is no registered company number on the Northampton Marketing website (company websites must display the registered company number).It was Northampton Marketing – “we are a small team with many years of experience” –that designed the MBMF website, according to the “Thank You” page on the fund website.

The Royal British Legion confirmed to me in an email that it’s granted permission to the MBMF to raise money on its behalf. But the UK’s largest military charity refuses to explain why it’s happy to work publicly with an organisation that isn’t a registered charity. The lack of accountability from the venerable Legion on use of its name and public protection is disappointing.

There’s a final concern about the fund not being a registered charity. There are significant financial (tax) benefits of being a registered charity. Why exactly is the MBMF choosing to forgo those financial benefits?

Two days after publication of my last post, Soldiers Off The Street has now changed what it says on the website about the alleged fundraising office (see para 15 in last post).

The charity has added an asterisk and footnote. The footnote states: “The fundraising office shown in the picture is the fundraising company the charity uses not the charity.” (screen shot in Figure 1).

Freedom of Information requests show that although officially based in Rhyl, north Wales, the charity Soldiers Off The Street – or persons acting in its name – has recently appliedto two local authorities for a street collection permit specifying as the charity address one of twoaddresses in Blackpool FY4. Both applications were successful and funds duly raised from the public – days apart – in different parts of the UK. This despite the fact that neither of the Blackpool addresses is on the public record for the charity. There is nothing about Blackpool on the Soldiers Off The Street website at date of publication either. Both local authorities thus failed to conduct due diligence on the applications, it seems. Further details in the applications show that there is an urgent need for clarity and transparency around both where Soldiers Off The Street is actually based and how it organises fundraising, particularly the role of subsidiary Soldiers Off The Street Fundraising Limited.The charity is unresponsive: it won’t even tell me via email the location of the alleged fundraising office in the photo on the website.

As you can see, at October 2015 Mr Murray told the South Wales Argus newspaper that Soldiers Off The Street has bases in Rhyl, Scotland, Lincolnshire and the Midlands. Nothing about Blackpool, then. There’s something else the chairmansaid: the fundraiser Mr Davies met in Monmouth had been employed by an “agency” to collect funds for the charity. In other words, the fundraiser was paid.

Soldiers Off The Street isn’t a member of the official umbrella organisation for military charities, the Confederation of Service Charities (Cobseo). Cobseo director of operations, Cdr Debbie Whittingham, told me in an email that the charity has made it clear to her it will never apply for membership.

On 23-25 November 2015, I encountered groups of people in military camo trousers collecting donations for Soldiers Off The Street in Manchester city centre, on busy Market Street. Two solicitations I repeatedly heard were “collecting for injured soldiers” and “help the soldiers”. Having confirmed with the licensing section of Manchester City Council (MCC) that it had authorised this fundraising, I obtained via a Freedom of Information request the application that the council had approved for the street collection permit. Here is MCC‘s redacted document: http://1drv.ms/1R1iIEM.

The first thing to notice is the charity address on the documents. Soldiers Off The Street is located in Rhyl, north Wales, according to both the public register at the Charity Commission and the charity website. Yet the documents specify the charity address as one of twoaddresses in Blackpool FY4. Both applications were successful and funds duly raised from the public – days apart – in the north west (Manchester city centre)and the west midlands (Dudley town centre). This despite the fact that neither of the Blackpool addresses is on the public record for the charity. There is nothing about Blackpool on the Soldiers Off The Street website at date of publicationeither. Both local authorities thus failed to conduct due diligence on the applications, it seems.

The application to MCC is the most revealing – because its form is the more demanding. The application to MCCshows the charity – or persons acting in its name – without explanation using the term “SOTSFR” in the address for Soldiers Off The Street. This is concerning because Blackpool FY4 company SOTSFR recently advertisedfor paid “face-to-face fundraisers” on the Indeed jobs website (screen shot in Figure 1). Note the “excellent rates of pay”. Yet the application to MCC states that the collectors won’t be remunerated out of the proceeds of the collection. In fact, there is no company called SOTSFR registered at Companies House.

The relationship between SOTSFRand the charity is even more opaque. As the application to MCCand other evidence shows, the charity – or persons acting in its name – often uses the domain name sotsfr.org.uk for email addresses. This despite the fact that theSoldiers Off The Street website is http://www.soldiersoffthestreet.org, according to the public register at the Charity Commission. The same charity website is at www.sotsfr.org.uk too (screen shot in Figure 2). Publicly available documents show that Soldiers Off The Street routinely uses the email address events2@sotsfr.org.uk, in particular. The charity did so when it was a trade stand exhibitor at the GWCT Scottish Game Fair (http://www.scottishfair.com), for example – in 2013 (screen shot in Figure 3) and 2014 (screen shot in Figure 4). Note also how the stated location of the charity varies: Preston (see below) in 2013 and Rhyl in 2014. The mobile phone number is nevertheless the same both years.

The registrant of the domain name sotsfr.org.uk is Force10 IT Solutions Ltd: a UK individual at a Blackpool address, according to the WHOIS information. Although the company Force10 IT Solutions Ltd was dissolved in November 2005, sotsfr.org.uk was registered in April 2012. The registered office address of the company was in Preston and one of its directors was William Knight. Mr Knight is now a director of the firm Soldiers Off The Street Fundraising Limited (registered company number: 08361891), registered address also in Preston. The other director is Patrick Jarrett. In November 2012, Mr Knight and Mr Jarrett were two of three men cleared of fraud raising money for wounded soldiers as their Blackpool-based company Wounded Warrior Project UK Ltd: www.blackpoolgazette.co.uk/news/crime/men-cleared-of-soldier-charity-fraud-1-5104735. (The street name for Mr Knight in the newspaper report is the same for the registrant of the domain name sotsfr.org.uk, according to the WHOIS information.)

Note: the registered office address of Soldiers Off The Street Fundraising Limited has never been in Blackpool; both addresses it has used to date are in Preston, according to Companies House records.

Available online, an apparentjob ad dated 20 February 2013 from Soldiers Off The Street Fundraising Limited for field sales/fundraiser explains the company is “a wholly owned subsidiary of the charity Soldiers Off The Street” (screen shot in Figure 5). Note both the Preston address and the email address bill@sotsfr.org.uk, which is presumably Bill (William)Knight.

Figure 5. Soldiers Off The Street Fundraising Limited field sales/fundraiser job ad at 23 December 2015

Soldiers Off The Street Fundraising Limited was incorporated 15 January 2013 with the charity as shareholder of the single £1 share. In January 2015, the company was nearly struck off the public register, according to Companies House information. Not a good sign. The charity has filed two sets of annual accounts at the Charity Commission since date of incorporation of the subsidiary – for financial years end 28 August 2013 and 28 August 2014. Astonishingly, in both years neither the charity trustees’ annual report nor the attached charity accounts refer in any way tothe company Soldiers Off The Street Fundraising Limited.Why not?

There is no mention of Soldiers Off The Street Fundraising Limited onthe charity website at date of publication and in either of the applicationsfor a street collection permit. The term “SOTSFR” appears without explanation in the address for Soldiers Off The Street in the application to MCC, though.

Soldiers Off The Streetis unresponsive. There is a photo on the charity website of what is referred to as the fundraising office, “the hub of all our fundraising around the UK” (screen shot in Figure 6). Its location isn’t disclosed, though. Soldiers Off The Street won’t say where the alleged fundraising office is: I have twiceasked in emails to both the address listed on the public register at the Charity Commission and events2@sotsfr.org.uk. I haven’t received a response from either address at date of publication.

Figure 6. Charity “fundraising office” at 19 January 2016

Soldiers Off The Street has received much scrutiny because of the charity’s alleged links to the BNP. But here I show that there is an urgent need for clarity and transparency around both where Soldiers Off The Street is actually based and how it organises fundraising, particularly the role of subsidiary Soldiers Off The Street Fundraising Limited.